Update on EPA Industrial Surface Coating MACT Residual Risk and Technology Review  

Earlier this month, the U.S. Environmental Protection Agency (EPA) released a Notice of Proposed Rulemaking for Maximum Achievable Control Technology (MACT) standards  for Surface Coating of Large Appliances, the Surface Coating of Metal Furniture, and the Printing, Coating, and Dyeing of Fabric and Other Textiles.

EPA will likely propose amendments to the Metal Can; Metal Coil; Auto & Light Duty Truck; Miscellaneous Metal and Plastic Parts Surface Coating Rules in the next few months. In addition, EPA will propose amendments to the Boat Manufacturing and Paper and Other Web MACT rules in early 2019.

EPA developed numerous MACT standards for Surface Coating between 1995 and 2004. These rules set standards for Hazard Air Pollutant (HAP) at major source coating application facilities. EPA is required to conduct a Residual Risk and Technology Review (RTR) for each MACT standard eight years after promulgation. EPA is concluding the RTR process for several MACT standards.

The RTR requires EPA to review the MACT standard to determine if additional tightening is necessary to eliminate any significant “residual risks” to public health that might remain despite the application of the MACT Standard. Under the residual risk review, EPA must evaluate the risk to public health remaining after application of the technology-based standards and revise the standards, if necessary. Revisions to a MACT standard must provide an ample margin of safety to protect public health or to prevent an adverse environmental effect. During the decision-making process EPA considers cost, energy, safety, and other relevant factors. Under the technology review, EPA must review the technology-based standards and revise them ‘‘as necessary.”  EPA has determined that revisions would be considered necessary if there were technological developments in practices, processes, and control technologies. Finally, EPA can also set new MACT standards as part of the RTR process.

A summary of the three rule proposals indicates that EPA is not proposing to lower the HAP limits in the rules, however EPA is proposing to:

  • Eliminate startup, shutdown and malfunction (SSM) Exemptions;
  • Require high efficiency spray application equipment for those facilities that spray apply coatings without the use of permanent total enclosures and air pollution control devices; and
  • Require facilities to submit electronic copies of compliance reports, including performance tests.

EPA is seeking comment on a requirement to retest control equipment anytime there is a process change that may adversely affect compliance with an emissions limit.

ACA and its Industrial Coating Air Regulatory Committee will review and submit comments on any proposed changes to MACT standards. ACA will also coordinate comments with downstream coating application associations.

Contact ACA’s David Darling for more information.

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